Privacy Policy

Effective: June 12, 2023

Mega Particle, Inc, a Delaware corporation and its subsidiaries Mega Particle Ltd and Mega Particle Spain SL (“us”, “we,“our”, or “Company” ) operates Poker VR, a virtual reality poker game. This page informs you of our policies regarding the collection, use and disclosure of personal Information as well as game related information we receive from users of Poker VR. We use your Personal Information only for providing and improving the game. By playing Poker VR, you agree to the collection and use of information in accordance with this policy. Please read this privacy policy carefully to understand our practices regarding the collection and treatment of your information. Do not play Poker VR unless you consent to the collection, maintenance and use of your information as described in this privacy policy.

Personal Information

We may collect personal information from you in accordance with this privacy policy and applicable law. How we collect personal information and our policies governing its use, deletion and disclosure are described in this privacy policy. “Personal information” refers to any information that can be used to personally identify you, such as your name, email address, address, voice, IP address, “personal data”, etc. (as that term is defined Article 4(1) of the General Data Protection Regulation), other identifiers by which you may be contacted online or offline, and other similar types of information under applicable law. Additionally, “Personal information” may include some non-personal information when it is linked with other types of personal information or non-personal information (e.g., motion sensor information or motion tracker information).

When you play Poker VR, we may collect information from you in the following ways:

Information from Third Party Platforms. We may automatically receive your personal information from the platform through which you downloaded and play the Game (e.g. Oculus, Steam). Personal Information collected by the third-party platform that you use to access the Game is subject to the applicable third-party terms of use and/or privacy policy (for more information, please see the Oculus Privacy Policy, Steam Privacy Policy Agreement as applicable). For instance, when you first play the Game using the Oculus store, your Oculus ID will automatically be transmitted to us, with no action on your part.  Our use of your personal information collected through the Game is limited to the purposes described in the “How We Use Your Information” section below.

Revealing personal information in Poker VR. You may choose to reveal personal information in the game through multiplayer chat or other public functions, including through your username. In addition to being accessible to other users of the game with whom you are interacting, we may also capture this information using recording functions that we use to monitor users’ activity in the game. We cannot control how other users will use personal information that you reveal using multiplayer chat or other public functions, so, if you reveal personal information through multiplayer chat or other public functions, you are doing so at your own risk. Similarly, users must not create a username that reflects their own real name or reveals personal information. If you include personal information in your display name, you are doing so at your own risk.

Cookies. We may use cookies in connection with automatic data collection through the Website. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you access the Website.

Data Processing

All information that you provide to us is stored on secured servers located in the United States of America. No matter where you are, you consent to the processing and transferring of your information, including personal information, in and to the United States of America and other countries. Laws that apply to the collection, maintenance and use of information in the United States of America (or any other country) may not be as comprehensive or strict as the laws of the country where you’re located.

Use of Personal Data

Some jurisdictions may require us to describe our legal bases for using or disclosing personal data that we may possess. Where such laws apply, our legal bases for processing personal data are as follows:

• Fulfillment of the purposes for which you have provided your consent;
• Compliance with the applicable law;
• Exercise of our legitimate interests in:

• Providing a safe and fun experience for everyone that plays Poker VR;
• Responding to customer service inquiries and providing customer service;
• Improving the game and business;
• Addressing legal issues.

• Fulfillment of our contractual obligations to users of the Game; and
• Working to protect you and other users.

Our policy is to use your information in a way that is consistent with and subject to this privacy policy.

Where you’ve provided information to us for a specific purpose (e.g., to help us troubleshoot an issue you’re having with the Service), we’ll use your information in furtherance of that purpose.

We, including our affiliates and subsidiaries, may also use your personal information:

• To offer, operate, maintain, and improve the Services;
• To present the Services to you;
• To operate all features within the Services;
• To investigate violations of our Terms of Service and attempt to prevent additional violations;
• To provide you with notices about your registration;
• To notify you about changes to the Services or any of our related products or services;
• For any other purpose with your consent.

Also, where you have given us permission to do so, we may use your information to send you news and updates about our products or services, including special offers and promotions. When we send you news or updates, we’ll also tell you how to opt out of receiving such notices.

Disclosure of your personal information

We do not share or otherwise disclose your personal information with or to third parties except:

• With your consent;
• As may be necessary to protect your safety or the safety of other users;
• To our affiliates and subsidiaries, to the extent consistent with this privacy policy, and who treat the information in confidentiality;
• To our lawyers, consultants, accountants, business advisors and similar third parties who owe us duties of confidentiality;
• In the event of a sale, merger, reorganization, bankruptcy, dissolution or other similar event, where the information of users is among the assets to be transferred;
• To enable us to take precautions against liability;
• To protect the safety and security of the Services;
• Where required to do so by law or legal process; or
• Where it is in aggregated and/or non-personally identifiable form.
• Your voice data may be captured through your microphone. We typically do not store this information, but we reserve the right to process it for moderation purposes. For moderation, specific voice data may be recorded and shared with a third-party service for additional processing. These recordings are anonymized and retained for a period of 35 days to ensure anonymity and compliance with regulations.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. When you directly provide us with personal information, including through registration, we will encrypt that information using secure socket layer technology or similar technologies. We may retain data collected from you, including personal information, to support customer service inquiries and prevent repeated violations or suspected violations of the Terms of Service if your account has been banned or your access to the Services has been disabled for any reason. We may retain your information for as long as is necessary and relevant to your use of the Services and our operations, which may include retaining your information beyond the end of your use of the Services. To dispose of personal information, we may anonymize it, delete it or take other measures we deem to be appropriate. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures used in the Services.

Data Subject Rights

We aspire to respect the privacy rights of all users, regardless of where they live. Accordingly, except as otherwise provided in this privacy policy, we will promptly act on users’ requests that we:

• Confirm that we have their personal data;
• Provide them with access to their personal data that we possess, including in portable format;
• Correct, update or amend their personal data;
• Delete and “forget” their personal data;
• Object to our use or disclosure of their personal data; and
• Limit our processing of their personal information.

Users may withdraw any consent they have provided us to process their personal information. Exercise of any of the rights listed in this section usually doesn’t apply retroactively from the date of the request and doesn’t affect our ability to continue processing information lawfully. Note that the rights enumerated in this section have certain limitations and exceptions under applicable law.

If you’d like to exercise any of the data subject rights described in this section, please reach out to us by email at support@megaparticle.com. We may use your personal information to verify your identity before acting on your request.

Lastly, users will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. However, we’d much rather you contact us first, so we can try to address any concerns that you have about our privacy practices.

CHANGES TO PRIVACY POLICY

We may update this privacy policy from time to time, so please review it frequently. We will post any new or updated privacy policy on our Website, make the new privacy policy accessible in Poker VR and attempt to notify you by email using the email address provided to us through the registration process, if applicable.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.